The automation of your "Country-by-Country" reporting

Base Erosion and Profit Shifting (BEPS)

Action 13 of the OECD/G20 BEPS project “Guidance on Transfer Pricing Documentation and Country by Country Reporting” can be considered to be one of the key deliverables. The action proposes to enhance transparency for tax administrations and contains revised standards for transfer pricing documentation and consists of three layers of documentation:

  1. a global Masterfile for transfer pricing
  2. a local transfer pricing documentation file
  3. a Country by Country report consisting of two tables

This 3rd layer –the Country by Country or “CbC” report provides a challenging set of instruments in the hands of the tax authorities. Although the CbC is not seen as a “information set defining the facts on which taxation takes place”, it does cover:

  • a full and transparent value chain description
  • the “taxable amount” allocated to each step in the value chain
  • any location where no / limited tax is being paid
  • where your “people functions” are taking place and
  • certain other measures of economic activity.

As a consequence of this detailed information, we expect Multinationals to prepare today for a multitude of queries from tax authorities and possibly other stakeholders. Furthermore, as a response, different “being in control” statements are being launched to the market place to facilitate Multinationals to remain in the “drivers’ seat” on their global transfer pricing risk position.

TPA together with TPH/Pebbleage provides the solution to collect the required CbC data fully automated.
The webinar will address the following topics:

  • address a practical way to source & automate Country by Country data collection
  • provide all participants with a Country by Country instruction manual
  • provide solutions on how to complete the 2 tables requested by the tax authorities
  • provide disclosure options to be discussed with your CFO
  • run a list of FAQ per category of stakeholders

During the webinar we will show you a demonstration on:

  1. data retrieval process;
  2. population process of 2 tables;
  3. data sources being used & process steps to convert sources to output tables.

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Transfer Pricing Associates BV.
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